American Democracy Legal Fund has filed a complaint with the Federal Election Commission alleging Donald Trump’s Director of the Office of Management and Budget Mick Mulvaney has been illegally using his campaign account for person gain. The Federal Election Campaign Act of 1971 strictly forbids any person from converting campaign funds to personal use or for any expense that would exist without a candidate’s campaign or federal officeholder duties. Since leaving Congress, Mulvaney has spent tens of thousands of dollars on personal expenses in an apparently brazen violation of the law.

“There might be no better example of the shamelessness and hypocrisy of the Trump White House than Mick Mulvaney using his campaign account as a slush fund for private clubs and fancy restaurants while telling Trump voters he’s busy draining the swamp,” said ADLF’s Brad Woodhouse. “The Trump administration is the most corrupt in my memory and each day we find new ways those closest to Trump are violating the public trust.”

As outlined in the complaint, there is precedent for the FEC punishing Mulvaney’s actions. One of Mulvaney’s predecessors as OMB Director sought permission to use campaign funds to pay for transition activities when leaving Congress and joining OMB but was denied. The FEC drew a sharp distinction between paying bona fide campaign operating expenses, and paying expenses that would have existed regardless of whether he had run for or served in Congress. The first was allowed—but the second was not.

In addition to $35,000 paid to Huckaby Davis Lisker for “Compliance Consulting,” Mulvaney’s non-existent campaign made two identical payments to a Republican private club billed as “your home away from home.” Some of the other dubious disbursements from Mulvaney’s account include:

$1,984.86 to Eric Bedingfield—Mulvaney’s former deputy chief of staff and campaign manager—for “Strategic Consulting” on July 28, 2017

$769.78 to Starboard Communications Inc for “direct mail” on March 22, 2017

$750 to Al Simpson—Mulvaney’s former chief of staff, who joined the lobbying firm Mercury LLC9—for “Strategic Consulting” on June 21, 2017

$541.02 to the Capitol Hill Club for “Meeting Expenses” on June 1, 2017

$541.02 to the Capitol Hill Club for “Catering” on July 17, 2017

$457.87 to Gula Graham, a fundraising consultant, for “Travel” on February 28, 2017

Since 2016, the Mulvaney for Congress’s FEC reports lack of any recorded debts or obligations, or any officially-connected expenses, meaning the above expenses could only have been incurred after Mulvaney went into the Trump Administration, and cannot have been incurred in connection with the winding-down of his House office or his former House duties.